Retrofitting of mirrors to hgvs

Transcription

1 FTA Compliance Guide Retrofitting of mirrors to hgvs EDITION 1 Ensuring compliance, advancing performance

2 FTA Retrofitting of mirrors to hgvs compliance guide Edition 1 August 2008 Editor: Andrew Mair Production: Hilary Kingdon Design: Tim Holdstock Cover picture: Courtesy of Brigade Electronics plc FTA compliance guides are produced once legislative changes have been published and new requirements and responsibilities are known. Compliance guides are intended to provide clear guidance to members on what to do and how to comply. Freight Transport Association 2008 FTA compliance guides are available only to FTA members. For further advice on this guide contact the Member Advice Centre on For details of how to join FTA contact the Member Service Centre on * Introduction New Directive 2007/38/EC on the retrofitting of mirrors to heavy goods vehicles registered in the European Union. The EU published Directive 2007/38/EC requires certain vehicles over 3.5 tonnes to be retrofitted with proper devices in order to improve the driver s field of vision and increase vehicle safety. The deadline for retrofitment of mirrors or other devices is 31March *Calls may be recorded for training purposes Contents Introduction 2 Background and objectives of the directive 3 Existing legislation 3 New requirements of directive 3 Exemptions 3 Vehicles previously derogated from Directive 2003/97/EC 3 Identifying typical class IV and V mirrors 3 Fields of vision 3 Retro fitment of mirrors 4 Testing criteria and VOSA position 4 Questions and answers 5 Further information 5 Retrofitting of mirrors to hgvs flowchart 6 2 FTA Retrofitting of mirrors to hgvs compliance guide

3 Background and objectives of the directive The directive aims to improve the safety of road users, in particular vulnerable road users such as pedestrians, cyclists and motorcyclists. This group bears a greater risk of being involved in accidents with large goods vehicles, which have a blind spot on the passenger s side. Legislation making an improved set of mirrors mandatory from 2007 onwards for new large goods vehicles is already in place. However, existing trucks remain in circulation without any improvement of their field of indirect vision. The new directive extends the requirements for the field of indirect vision to the existing fleet of large goods vehicles. Existing legislation Under Directives 2003/97/EC and 2005/97/EC new goods vehicles over 7.5 tonnes and certain goods vehicles between 3.5 and 7.5 tonnes registered from 26 January 2007 had to be fitted with an increased number or improved mirrors in order to reduce blind spots. New requirements of the directive Directive 2007/38/EC requires heavy goods vehicles to be fitted retrospectively with enhanced devices, for example mirrors, so as to reduce the number of fatal accidents involving vulnerable road users. This directive applies to vehicles over 3.5 tonnes which are not type approved or approved as a single vehicle under the 2003 directive. Most vehicles over 3.5 tonnes not already complying with the 2003 directive must be retrofitted, on the passenger s side only, with improved devices for indirect vision. These devices must meet 95 per cent and 85 per cent of the vision required under the 2003 directive for class IV (wide angle) and class V (close proximity) mirrors respectively. Light goods vehicles below 3.5 tonnes and buses are not covered by the directive. Class VI front mirrors which became mandatory on vehicles over 7.5 tonne from 26 January 2007 are not required to be retrofitted under this directive. a load corresponding to its maximum technically permissible weight the mirror is fully visible from the driving position Vehicles already retrofitted Vehicles over 3.5 tonnes that are subject to national measures which entered into force before the dates for transposition of Directive 2003/97/EC and which require fitment, on the passenger side, of other means of indirect vision covering not less than 95 per cent of the total field of vision at ground level of class IV and class V mirrors under that directive. This refers to member states such as Netherlands, Belgium and Denmark where retrofitment legislation already applies Vehicles previously derogated from Directive 2003/97/EC It is estimated that there are around 4,500 end of series UK vehicles manufactured before 26 January 2007 which were previously derogated from the requirements of the 2003 directive. These vehicles will need to be retrofitted and comply with the new 2007 directive. Vehicle owners should contact the relevant manufacturer who will be able to clarify if their vehicle was previously derogated and will now need to comply. Identifying typical class IV and V mirrors Class V mirror (Close proximity mirror) Class IV mirror (Wide angle mirror) Exemptions This directive does not apply to the following categories. Older vehicles Vehicles over 3.5 tonnes registered before 1 January 2000 Low cab vehicles Vehicles over 3.5 tonnes having a maximum total permissible mass not exceeding 7.5 tonnes, where it is impossible to mount a class V mirror in a way that ensures that the following conditions are fulfilled: no part of the mirror is less than 2m (a tolerance of +10cm may be applied) from the ground, regardless of the adjustment position, when the vehicle is under Fields of vision In order for operators to check compliance of vehicles within scope of the new 2007 directive, a field of view check will need to be carried out. The 2007 retrofitment directive requires no less than 95 per cent of the field of vision at ground level of a class IV wide angle mirror and not less than 85 per cent of the field of vision at ground level of a class V close proximity mirror. FTA Retrofitting of mirrors to hgvs compliance guide 3

4 25m Area A Class IV wide angle mirror field of vision 10m Driver s eye line Bird s eye view of required field of vision complying with Directive 2003/97/EC for class IV and class V mirrors Field of vision check 15m A field of vision check can be carried out by placing visible markers at the points shown on the diagram above. The two defined areas of vision can then be checked from the driver s seat. Mirrors will need to be adjusted until all of the area within markers can be seen; this will give the field of view required. Class IV wide angle mirror From your position in the driver s seat, if you can see 95 per cent of the shaded area marked Area A within the markers at ground level through the exterior mirror/s you have a compliant field of vision for the class IV wide angle mirror under the new 2007 directive. Close proximity mirror 2.75m 4.5m Area B Class V close proximity mirror field of vision From your position in the driver s seat, if you can see 85 per cent of the shaded area marked Area B within the markers at ground level through your close proximity mirror you have a compliant field of vision for the class V close proximity mirror under the new 2007 directive. TE: If you have no close proximity mirror fitted but you can see the shaded area marked Area B through a combination of other mirrors and wide angle mirror, you do not need to fit a class V mirror. Retrofitment of mirrors Some manufacturers can offer replacement mirror glass which fulfils the requirements of the 2003 directive with regard to curvature and vision, and can be fitted into existing mirror 2m 1m 1.5m 1.75m housings. This applies to specific makes and models, and depends on the year of build. Other manufacturers vehicles cannot be retrofitted by merely exchanging the mirror glass because of the geometry of the mirror housings, and there are cases where mirror arms and mountings will need to be replaced. Some manufacturers have mirrors profiled to a specific radius which are compliant with the requirements of the directive and can supply a simple profile gauge for vehicle operators to check compliance. Other manufacturers have a specific list of approved mirrors which comply. Vehicles within scope of this directive, particularly for which technical solutions are not available or economically viable, may be equipped with supplementary mirrors and/or other devices of indirect vision (such as cameras and monitors etc), provided that the combination of such devices covers not less than 95 per cent of the field of vision at ground level of a wide angle mirror and not less than 85 per cent of the field of vision at ground level of a close proximity mirror under Directive 2003/97/EC. It is important to stress that the directive is a field of view directive and specifies a defined area around the vehicle which must be in view from a particular eye position. Therefore fitment of correct mirrors alone does not guarantee that full compliance of the field of view will be met as it will depend on the positioning of the mirror. Testing criteria and VOSA position The Vehicle and Operator Services Agency (VOSA) has agreed with the Department for Transport on how compliance of the directive at annual test will be enforced. VOSA has proposed that from 1 April 2009, operators will need to complete a self-decleration certificate stating that the vehicle is equipped on the near-side with mirrors or such devices which fully comply with the relevant articles of Directive 2007/38/EC and present this at annual test. This will be a one off presentation of the certificate and will not be required on subsequent tests. The certificate should be retained with the vehicle s registration document for when the vehicle is sold. Operators will need to fit mirrors or other devices and carry out a field of vision check to confirm compliance to the directive, and complete the self-declaration certificate. To help operators and drivers check their field of view, a guide will be available to download from the Transport Office. www. transportoffice.gov.uk VOSA will also be producing a leaflet describing the changes. VOSA examiners will then carry out a check of the selfdeclaration certificate and mirror checks against current standards to ensure roadworthiness. If in the opinion of the VOSA examiner it is clearly obvious that mirrors do not comply with the requirements of the directive, a physical check of the mirror profile may be carried out. VOSA has stated that it has no plans to introduce checks of retrofit mirror certificates at roadside. VOSA also does not intend any changes to the current policy of checking mirrors at roadside checks in line with Categorisation of Defects criteria. 4 FTA Retrofitting of mirrors to hgvs compliance guide

5 Questions and answers Existing vehicles Q My vehicle was registered after 26 January 2007 and already complies. Do I need to do anything? A Compliant vehicles which are registered post 26 January 2007 are not subject to any changes and do not require self-declaration certificates. However, vehicle owners should contact the relevant manufacturer who will be able to clarify if their vehicle was one of the end of series vehicles previously derogated from the 2003 directive and will now need to comply with the 2007 directive. Q What options, other than original manufacturer s mirrors, are there in order for my vehicle to comply? A There are many after market mirrors which can be fitted in order to achieve compliance. CCTV is also an option. Pre-owned vehicles Q How do I check that a vehicle I buy second-hand is compliant? A Ask to see the self-declaration certificate and retain it. It will be required to be presented at the vehicle s first annual test post 31 March (It would be prudent to carry out a field of view check to validate the certificate.) If no certificate is available, check compliance to the required field of view using the guide issued by VOSA. If the field of view is met, then carry out self-certification. If not, mirrors/devices of the correct type will need to be fitted. Enforcement Q Will retrofit mirror certificates be checked at the roadside? A VOSA has stated that it has no plans to introduce checks of retrofit mirror certificates at roadside. Q If my vehicle comes up for test in September 2009 and requires additional mirrors, I intend fitting them at the time of test. Will it fail at the roadside if checked after 31 March 2009 before the extra mirror is fitted in September? A VOSA has stated that it has no plans to change the current policy of checking mirrors at roadside checks, therefore providing the vehicle complies with current Categorisation of Defects criteria, the vehicle would not fail. However, it is a legal requirement to comply with the requirements of the directive with immediate effect post 31 March Non compliance could result in action by the Health and Safety Executive and possible civil claims should vehicles be involved in accidents. Further information Directive 2007/38/EC is available for downloading at: FTA Retrofitting of mirrors to hgvs compliance guide 5

6 Retrofitting of mirrors to hgvs flowchart Vehicle over 3.5t? Registered before 1 January 2000? Do nothing not in scope Vehicle t with a low cab concession (see Exemptions, page 3)? Vehicle registered before 26 January 2007? Did vehicle have an end of series concession from 2003 directive (see Exemptions, page 3)? Do nothing already complies with 2003 directive Does vehicle already comply (see Fields of vision, page 3)? Fill in self-certification form (see Testing criteria and VOSA position, page 4) by 31 March 2009 Ensure mirrors or other indirect vision equipment fitted to comply with 2007 directive (see Retrofitment of mirrors, page 4) and fill in self-certification form (see Testing criteria and VOSA position, page 4) by 31 March FTA Retrofi tting of mirrors to hgvs compliance guide

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